WEBSITE PRIVACY POLICY (WASHINGTON)

Effective Date: 1/2/2026

WEBSITE PRIVACY POLICY (WASHINGTON)

Last Updated: [DATE]

This Website Privacy Policy (this “Privacy Policy”) describes how Fletcher Quill Group Inc., a Washington corporation (“FQG,” “Company,” “we,” “us,” or “our”), acting on behalf of itself and its affiliated entities, including Fletcher Quill Inc., Fletcher Quill Estates Inc., and Fletcher Quill Global Inc. (collectively, the “Fletcher Quill Entities”), collects, uses, stores, protects, and discloses personal information when you access or use our website located at fletcherquillgroup.com (the “Site”), and any related applications, platforms, or services, including the Ink Scratch software-as-a-service application and the Optimize Living community and property services (collectively, the “Services”).

This Privacy Policy is intended to comply with applicable Washington State law, including the Washington My Health My Data Act (MHMD) where applicable, Washington consumer protection principles, and applicable federal privacy laws.

1. SCOPE AND ACCEPTANCE

1.1 Scope of This Privacy Policy

This Privacy Policy applies to all visitors, users, customers, subscribers, tenants, members, and other individuals who access or use the Site or Services (collectively, “Users”). It applies regardless of whether you are accessing the Site as a consumer, business customer, contractor, or representative of an entity.

1.2 Acceptance of Policy

By accessing or using the Site or Services, you acknowledge that you have read, understood, and agree to the collection, use, storage, and disclosure of your information as described in this Privacy Policy. If you do not agree, you should not use the Site or Services.

1.3 Relationship to Other Agreements

This Privacy Policy operates in conjunction with, and does not replace, our Terms of Service, Master Sales and Service Agreement, lease agreements, membership buy-in documents, employment agreements, or nondisclosure agreements, which may govern specific relationships.

2. INFORMATION WE COLLECT

We are committed to data minimization and collect only the personal information reasonably necessary to provide our Services, process payments, manage subscriptions or tenancy, comply with legal obligations, and protect our business.

A. Personal Information You Provide Directly

We may collect the following categories of personal information when you voluntarily provide it to us:

1. Identifiers and Contact Information

• Full legal name
• Mailing and billing address
• Email address
• Telephone number

2. Billing and Transactional Information

• Subscription details related to Ink Scratch
• Rental, lease, or membership-related details for Optimize Living
• Payment confirmation and transaction history

Important: All payment card and sensitive financial data are processed exclusively by Stripe. We do not store full payment card numbers on our servers.

3. Account and Service Information

• Subscription status
• Account preferences
• Communications with us regarding support or service inquiries

B. Information Collected About Minors

Certain Services, including educational versions of the Ink Scratch application, may be offered for use by minors.

• Parental or Guardian Consent Required: We collect personal information relating to minors only when a parent or legal guardian purchases a family or educational subscription.
• Verifiable Consent: Completion of the purchase constitutes verifiable parental consent under applicable law.
• Limited Use: Information relating to minors is used strictly for providing educational Services and maintaining account integrity.
• Identity Verification: Stripe’s identity and fraud-prevention tools are used to validate the purchasing adult.

We do not knowingly collect personal information directly from minors without parental consent.

C. Automatically Collected Information and Limited Tracking

When you access the Site, we may automatically collect limited technical information, including:

• IP address
• Browser type and version
• Device type
• Date and time of access

We use this information solely for security, functionality, and internal analytics. Any cookies or tracking technologies used are limited to what is reasonably necessary for Site operation and performance analysis.

3. HOW WE USE YOUR INFORMATION

We use personal information for legitimate business purposes, including:

3.1 Service Provision and Management

• To provide and maintain Ink Scratch subscriptions
• To administer Optimize Living rentals, leases, and membership buy-ins
• To manage accounts, subscriptions, and tenancy relationships

3.2 Payment Processing and Security

• To process payments securely through Stripe
• To prevent fraud and unauthorized transactions
• To verify identity where required

3.3 Communications

• To send service-related notices, confirmations, and updates
• To communicate about billing issues or account changes
• To respond to inquiries and customer support requests

3.4 Legal and Business Operations

• To comply with legal, tax, accounting, and regulatory obligations
• To enforce our agreements
• To protect the rights, safety, and property of the Fletcher Quill Entities and others

4. DATA STORAGE, RETENTION, AND DELETION

4.1 Data Minimization and Retention Periods

We retain personal information only for as long as reasonably necessary:

• Active Customers: Data is retained for the duration of the active subscription, lease, or membership, plus any legally required retention period.
• Inactive Customers: After termination, cancellation, or expiration, personal information is securely deleted, anonymized, or archived unless required for legal, tax, or auditing purposes.

4.2 Data Storage Locations

Operational data processing occurs primarily in Washington State, while certain affiliated entities are located in Wyoming. We use reputable cloud service providers and reasonable safeguards to protect data during storage and transfer.

5. SHARING AND DISCLOSURE OF INFORMATION

We do not sell personal information. We disclose information only as necessary:

5.1 Service Providers

• Stripe: For payment processing, fraud prevention, and compliance.

5.2 Corporate Affiliates

We may share information internally among the Fletcher Quill Entities for operational, administrative, IT, legal, and compliance purposes, consistent with our internal agreements.

5.3 Legal and Safety Obligations

We may disclose information when required to:

• Comply with legal process or governmental requests
• Enforce our agreements
• Protect the rights, safety, or property of Users or the public
• Prevent fraud or security incidents

6. DATA SECURITY

We implement reasonable administrative, technical, and organizational safeguards designed to protect personal information from unauthorized access, disclosure, alteration, or destruction.

• Payment information is secured through Stripe’s PCI-compliant systems
• Access to personal data is restricted to authorized personnel
• Security practices are reviewed periodically

However, no system can be guaranteed to be 100% secure.

7. YOUR RIGHTS UNDER WASHINGTON LAW

Washington residents may have the following rights, subject to applicable law:

• Right to Access: Request confirmation of whether we process your personal information
• Right to Correction: Request correction of inaccurate information
• Right to Deletion: Request deletion of personal information, subject to legal retention obligations
• Right to Withdraw Consent: Where processing is based on consent

Requests may be submitted using the contact information below. We will respond within a reasonable timeframe as required by law.

8. CHANGES TO THIS PRIVACY POLICY

We may update this Privacy Policy periodically. Material changes will be posted on this page with an updated “Last Updated” date. Continued use of the Site after changes constitutes acceptance of the revised policy.

9. CONTACT INFORMATION

If you have questions or wish to exercise your privacy rights, please contact:

Fletcher Quill Group Inc.
11700 7th Avenue Suite 2100

Seattle WA 98101-1360

privacy@fletcherquillgroup.com